Risk management and financial reporting issues
2010
Comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts (February 2010)
Comments to the NAIC on its draft memorandum, "Windows and Walls" Approach for Regulation of United States Based Insurers Operating within Corporate Groups (January 2010)
Comments on the Basel Committee on Banking Supervision's consultation document, Recognizing the risk-mitigating impact of insurance in operational risk modelling (January 2010)
2009
Financial Regulatory Reform Task Force comments on H.R. 2609, the Insurance Information Act, and H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009, recommending the creation of an Office of the Actuary (December 2009)
Comments to the NAIC on its draft paper, United States Insurance Financial Solvency Framework (December 2009)
Risk Management & Financial Reporting Council testimony supporting the establishment of a governmental systemic risk regulator (December 2009)
The Financial Reporting Committee comments to the IASB on its Exposure Draft, Fair Value Measurement (October 2009)
Slides and other information from an Academy Capitol Hill briefing on systemic risk (September 2009)
Life Financial Reporting Committee and Financial Reporting Committee comment to the IASB on its Exposure Draft, Financial Instruments: Classification and Measurement (September 2009)
The Financial Reporting Committee white paper, Notes on the Use of Discount Rates in Accounting Present Value Estimates (September 2009)
The Financial Reporting Committee comments to the IASB on its Discussion Paper, Credit Risk in Liability Measurement (September 2009)
IAA Insurance Accounting Committee and Financial Reporting Committee chairs present at a Financial Accounting Standards Board (FASB) educational session on risk margins (July 2009)
The Solvency Committee comments to National Conference of Insurance Legislators (NCOIL) on its credit default insurance model legislation (July 2009)
The Financial Reporting Committee comments to the FASB on its Discussion Paper, Preliminary Views on Revenue Recognition in Contracts with Customers (June 2009)
In written testimony submitted to the U.S. House Subcommittee on Capital Markets, the Academy highlights key concepts and elements that are needed for the effective oversight and monitoring of risks in the insurance industry (May 2009)
The Financial Reporting Commitee comments to the International Association of Insurance Supervisors (IAIS) on the Draft Issues Paper on the Roles of and Relationship Between the Actuary and the External Auditor in the Preparation and Audit of Financial Reports (May 2009)
Academy white paper outlining risk management requirements for effective systemic risk regulation (April 2009)
Academy responds to a New York Times article in which the FDIC agreed to guarantee billions of dollars in risky loans assuming that those loans represent zero default risk (April 2009)
Comments to the FASB on its Discussion Paper, Preliminary Views on Financial Statement Presentation (April 2009)
Response to the joint IASB/FASB Financial Crisis Advisory Group (FCAG) in which FCAG sought input from constituents to discussion questions surrounding accounting and reporting matters related to the financial crisis (April 2009)
The Academy issues Concepts for Successful Regulation of Systemic Risk, a white paper outlining risk management requirements for effective systemic risk regulation (April 2009)
Written testimony supporting a "systemic risk regulator" to prevent future financial meltdowns (March 2009)
Ccomments to the Securities and Exchange Commission on the Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by US Issuers. (March 2009)
Comments to International Accounting Standards Board regarding its Revenue Recognition project (February 2009)
Comments on NAIC Solvency Initiative (February 2009)
Testimony to NCOIL on Actuarial Principles, Risk Management Principles, and Insurance Principles for the Solvency & Risk Management of Credit Default Swaps (CDS) - Why and How? (January 2009)
2008
Letter to the Senate and House seeking clarification on the role of the actuary in the Insurance Information Act of 2008 (July 2008)
Comments on IAA draft concerning current estimates and risk margins in measuring insurance liabilities (May 2008)
Comments on IAA draft concerning current estimates and risk margins in measuring insurance liabilities (May 2008)
Practice note on the identification and valuation of embedded derivatives in modified coinsurance and similar insurance arrangements (February 2008)
Comment letter to the IASB on proposed ISA 620, "Using the Work of an Auditor’s Expert" (February 2008)
2007
Comments on the Treasury Department's proposed review of the U.S.
financial regulatory structure (November 2007)
Comments on an IASB discussion paper, “Preliminary Views on Insurance Contracts,” and on a related invitation to comment from FASB (separate documents, November 2007)
Comments on a draft NAIC model act concerning corporate governance for risk management (November 2007)
Comments to the SEC on a proposal to eliminate a requirement for reconciling IFRS
financial statements with U.S. GAAP (October 2007)
Presentation for NAIC work group on international solvency and accounting issues (August 2007)
Risk Management and Solvency Committee comments on several IAIS papers (August 2007)
Comments to IAA about exposure draft on current estimates and risk margins in measuring liabilities for insurance contracts (May 2007)
Comment letter to FASB on accounting for life insurance contracts acquired in a business combination (April 2007)
Academy/ASB response to a FASB request for comments on valuation guidance in financial reporting (April 2007)
Discussion paper on health premium deficiency reserves, with examples, common terms, and references to authoritative guidance (March 2007)
Comments on a new version of an IAIS paper about a common structure for insurer solvency assessment (January 2007)
2006
Exposure draft of practice note concerning AICPA Statement of Position 05-1 (December 28, 2006)
Comments on a revised IAIS paper about a common structure for insurer solvency assessment
Letter to congressional leaders on the legislative definition of a qualified risk manager (September 2006)
Comments to FASB on insurance bifurcation and risk transfer accounting issues (August 2006
Comments to the IAA about draft IAIS documents on asset-liability management and insurer solvency assessment (July 2006)
Letter recommending that any new federal insurance bill include a provision creating an Office of the Actuary. (July 2006)
Comments to the SEC on a proposed executive-compensation disclosure rule (April 2006)
Comments on a proposed GASB technical bulletin about the Medicare Part D retiree drug subsidy (April 2006)
Suggestions for revising a proposed IAA practice guideline oninsurance risk disclosure (March 27, 2006)
Response to a FASB invitation to comment on the treatment of liabilities and assets with uncertainties in financial reporting (January 2006)
2005
Financial Reporting Committee presentation at a FASB forum on phase 2 of the IASB’s insurance contracts project (Oct. 26, 2005)
Follow-up letter to GAO on the role of actuaries in insurance (June 29, 2005)
Comments on draft IAA practice guidelines for insurance contract financial reporting, current estimates, and investment contract measurement (February 2005)
Letter to the SEC on disclosure for p/c liabilities in financial reporting (Jan. 24, 2005)
2004
Comments on a proposed IASB standard about financial instrument disclosure (Oct. 22, 2004)
Comments on a proposed FASB standard for measuring fair value (September 2004)
Comment letter to the NAIC concerning international dicussions on fair value (July 28, 2004)
Comment letter about an IAIS draft standard on capital (July 1, 2004)
An addendum to a March 25 letter on an IAA framework for assessing insurer solvency (March 29, 2004)
A comment letter on an IAA framework for assessing insurer solvency (March 25, 2004)
Comments on an IASB proposal for international accounting standards for insurance contracts (October 31, 2003)
2003
Comments on an IASB proposal for international accounting standards for insurance contracts (October 31, 2003)
Suggested changes in FASB financial disclosure proposals for pensions and postretirement benefits (Oct. 27, 2003)
Comments to COSO about its draft enterprise risk management framework (Oct. 14, 2003)
Letter accepting an NAIC request to make recommendations on possible trend tests for casualty and health RBC (Sept. 5, 2003)
Role of the Actuary Under Federal Insurance Regulation (April 2003 monograph)
Supplement to a February 2002 comparison of the three NAIC RBC formulas (March 3, 2003)
Comments to the SEC on proposed Sarbanes-Oxley Act auditor independence rules (Jan. 6, 2003)
2002
Letter to GASB about a proposed accounting standard for post-retirement benefit plans (Dec. 13, 2002)
Commments to the SEC on proposed Sarbanes-Oxley Act disclosure rules (Dec. 3, 2002)
Comments on an AICPA proposed statement of position (Oct. 30, 2002)
Fair Valuation of Insurance Liabilities: Principles and Methods(September 2002 monograph)
Letter nominating Richard Robertson to the Public Company Accounting Oversight Board (Aug. 28, 2002)
Comments to FASB on cash balance accounting issues (Aug. 20, 2002)
Letter on the definitions of "actuarial services" and "appraisal or valuation and fairness opinions" in H.R. 3763 (July 19, 2002)
Comments on indemnity provisions in instructions for P/C statements of actuarial opinion (June 9, 2002)
Draft FAQs on the valuation of embedded derivatives in life and annuity contracts in accordance with FAS 133 (June 2002)
Comments on NAIC Issue Paper 118 (April 19, 2002)
Updated comparison of the NAIC's life, P/C, and health RBC formulas (Feb. 12, 2002)
2001
Comments on mapping terms for insurance risks and banking risks (Dec. 9, 2001)
Slides from an Academy presentation on risk management at the 2001 NAIC winter meeting (Dec. 9, 2001)
Form with suggested language changes to SSAPs (Nov. 16, 2001)
Written testimony from Casualty Vice President Steve Lehmann, prepared for the Senate Banking Committee as it considered terrorism insurance proposals (Oct. 25, 2001).
A letter to the House Financial Services Committee from Academy President Larry Johansen urges actuarial inclusion in proposed catastrophe loss comission (Oct. 9, 2001).
Comments to FASB on a proposed accounting standard for financial instruments (Sept. 21, 2001)
Comments on SSAP 54 (Aug. 29, 2001)
Letter to the NAIC on reserve requirements and SSAP 51 (Aug. 24, 2001)
Letter to IASB on hybrid financial instrument accounting treatment (May 29, 2001)
Comments on proposed changes to the "Accounting Practices and Procedures Manual" (May 18, 2001)
COLIFR's report on its GAAP survey (April 2001)
Comment on a FASB exposure draft concerning business combinations and goodwill accounting (March 16, 2001)
Before 2001
Primer on fair value issues, including a summary of a recent CAS research paper on fair value(December 2000)
UVS report by the Numerical Examples Group (September 2000)
Comments on the fair value section of an IASC issue paper (June 6, 2000)
Comments on proposed privacy rule (March 31, 2000)
Presentation to the NAIC's Life and Health Actuarial Task Force on viability analysis, with appendices A, A2, B, B2, C and D (June 2000)
Comments on proposed fair value accounting principles (May 31, 2000)
Letter on the review of RBC for assets (Feb. 4, 2000)
Academy Task Force on Banking and Financial Services (May 21, 1999)
Statement of the Task Force on Banking and Financial Services and the Financial Reporting Council of the American Academy of Actuaries on the Financial Services Modernization Act of 1999 (March 11, 1999)
Financial Services Modernization Letter to Rep. James A. Leach ( January 27,1999)
Academy Report on Impacts of H.R. 10 (June 2, 1998)
Equity Indexed Products (January 5, 1998)
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